Bingham

Bingham

Susan E. Seabrook

Partner

Susan Seabrook’s practice is concentrated in the area of federal tax controversy and litigation, with an emphasis on the special provisions applicable to the insurance, reinsurance and health care industries. Her insight and technical tax knowledge have guided clients to successful resolutions of complex tax controversy matters, frequently at an early stage of administrative development. She has extensive experience at all levels of tax administration and has tried numerous cases before the United States Tax Court. Susan has also advised clients in responding to congressional, regulatory and other governmental inquiries as well as provided advice in connection with insurance company and product-related tax implications of complex M&A transactions.

Prior to joining the firm, Susan served as an attorney adviser in the National Office of Chief Counsel, IRS, Financial Institutions and Products. As IRS industry counsel for the life insurance industry, she assisted in identifying and developing issues related to insurance company and product tax. Susan also served as an IRS senior trial attorney and special assistant United States attorney, specializing in insurance company litigation. Most recently, Susan joined us from Skadden, Arps, Slate, Meagher & Flom LLP.

Susan is a recognized insurance tax expert and was “recommended for all insurance and reinsurance controversy” by Legal 500.

Events

  • Moderator, Megatrends: Prognostications on Insurance Taxation, American Bar Association Tax Section’s May Meeting, Washington, D.C. (May 9, 2014)
  • Panelist, IRS Appeals Update, ABA Section of Taxation Midyear Meeting, Phoenix, Ariz. (Jan. 24, 2014)
  • Moderator, Tax Controversy Transformation: Best Practices for Minimizing Challenges and Maximizing Outcomes, Insurance Tax Conference, Chicago, Ill. (Nov. 15, 2013)
  • Speaker, Insurance and Reinsurance Transfer Pricing — Preparing for Tomorrow’s Tax Challenges Today, BNA Webinar (Nov. 7 and 21, 2013)
  • Panelist, New Rules Under Section 162(m)(6): Applying the $500,000 Deduction Limit for Compensation of Health Insurance Company Employees, Bloomberg BNA Webinar (May 22, 2013)
  • Moderator, Tax Controversy: Lessons Learned From Recent Cases, American Bar Association Tax Section’s May Meeting, Washington, D.C. (May 10, 2013)
  • Panelist, Tax Implications of the Affordable Care Act, Federal Bar Association Section on Taxation’s 37th Annual Tax Law Conference, Washington, D.C. (March 1, 2013)
  • Moderator, Life Insurance Tax Reserves: Missing the CARVM Forest for the AG Trees, and Speaker, Ask the Experts, Insurance Tax Conference’s 37th Annual Federal Tax Seminar, Chicago, Ill. (Dec. 7, 2012)
  • Speaker, Insurance Tax Industry Update, Insurance Tax Conference’s 37th Annual Federal Tax Seminar,  Chicago, Ill. (Dec. 6, 2012)
  • Panelist, Taxpayer Discussion of IRS Administrative Practice, Federal Bar Association Section on Taxation’s 24th Annual Insurance Tax Seminar, Washington, D.C. (May 31, 2012)
  • Panelist, Regulatory & Tax Update, Society of Actuaries’ Life & Annuity Symposium, Los Angeles, Calif. (May 21, 2012)
  • Panelist, Insurance Tax Litigation,  Insurance Companies Committee, American Bar Association Tax Section’s May Meeting, Washington, D.C. (May 11, 2012)
  • Panelist, Testifying Experts in Tax Litigation Forums, Federal Bar Association Section on Taxation’s 36th Annual Tax Law Conference, Washington, D.C. (March 2, 2012)
  • Panelist, The Far-Reaching Impact of FATCA Across Borders and Across Industries, American Bar Association Section of Taxation’s Midyear Meeting, San Diego, Calif. (Feb. 18, 2012)
  • Moderator, The Conformity Rule: From Standard Life & Accident to State Farm, Insurance Tax Conference’s 36th Annual Federal Tax Seminar, Chicago, Ill. (November 2011)
  • Presenter, Brave New World, Electronic Discovery From Audit to Litigation, Tax Executives Institute’s Spring Seminar, Nashville, Tenn. (April 2011)
  • Moderator, Specialized Uses of Insurance and Transactions to Manage Risk, American Bar Association Section of Taxation’s Midyear Meeting, Boca Raton, Fla. (January 2011)
  • Panelist, Economic Substance and Other Judicial Doctrines, Insurance Tax Conference’s 35th Annual Federal Tax Seminar, Chicago, Ill. (November 2010)
  • Moderator, Recent Developments in Life Insurance Reserves Taxation, Federal Bar Association’s Insurance Tax Seminar, Washington, D.C. (June 2010)
  • Co-Presenter, Managing Outside Tax Advisors, Tax Executives Institute, San Diego Chapter, San Diego, Calif. (March 2010)
  • Co-Presenter, Trends and Developments in Federal Tax Controversies, Tax Executives Institute, Arizona Chapter (March 2010)
  • Moderator, The Perfect Storm: Financial and Tax Regulatory Reform and the Effect on Convergence in the Financial Services Sector, Combined Committees Luncheon, American Bar Association Section of Taxation’s Midyear Meeting, San Antonio, Texas (January 2010)
  • Panelist, Penalty Update — IRS Policies and Practice, Insurance Tax Conference, Chicago, Ill. (November 2009)
  • Lunch Speaker, Coming Soon to a Transaction Near You — Why Tax Advisors Should Care About E-Discovery, University of Chicago Law School’s 62nd Annual Tax Conference, Chicago, Ill. (November 2009)
  • Moderator, Tax Controversy Update for Insurance Companies, American Bar Association Section of Taxation’s Fall Meeting, Chicago, Ill. (September 2009) 

 

Publications

  • Co-author, “Comments Concerning FATCA Regulations Relating to Insurance Issues,” ABA Section of Taxation (Jan. 24, 2014)
  • Co-author, “FATCA Regs Responsive to Some, But Not All, Insurers’ Concerns,” Tax Notes International (April 1, 2013)
  • Contributor, “Proposed Regulations Under the Foreign Account Tax Compliance Act (Insurance Companies),” American Bar Association (June 15, 2012)
  • Author, “Coming Soon to a Transaction Near You — Why Tax Advisors Should Care About E-Discovery,” Taxes − The Magazine (March 2010)

Memberships

  • Member, Board of Directors, Insurance Tax Conference
  • Former Chair, Insurance Companies Committee, American Bar Association, Tax Section
  • Barrister, J. Edgar Murdock (Tax Court), American Inns of Court
  • Adjunct Professor, University of Baltimore School of Law, Masters of Taxation Program (2003)

Awards & Honors

  • Legal 500, Tax Controversy (2009–2011, 2014)

Legal insight. Business instinct. Global intelligence. ®